I The proposed development is a 94-unit apartment complex, for which <br />2 respondent developer applied for site review, adjustment review, and a Willamette River <br />3 Greenway permit. After a public hearing, a city hearings official approved the <br />4 application, with conditions. With respect to the number of units, the hearings official <br />5 determined that the maximum permitted number of units was 94, given the net-density <br />6 provisions for the zone, based on 3.38 acres of property. In making that calculation, the <br />7 city "counted the entire 3.59-acre property and excluded only a 0.21-acre area to be <br />8 dedicated for the extension of Lombard Street." As relevant to this review proceeding, <br />9 the 3.38 acres is planned to include a leasing office, a maintenance building, and two <br />10 internal parking circulation areas. <br />11 Petitioners appealed to the Eugene Planning Commission, which affirmed <br />12 the hearings official's decision, with modifications. Petitioners petitioned for review to <br />13 LUBA, which affirmed the planning commission's decision. Petitioners now seek <br />14 judicial review. They raise a single assignment of error, in which they challenge the net- <br />15 density calculation for the proposed development, as they did in the city and LUBA <br />16 proceedings. Specifically, petitioners argue that, under EC 9.2751(1)(b), LUBA erred in <br />17 allowing land planned for a leasing office, a maintenance building, and two internal <br />18 parking circulation areas to be included in the net-density calculation. <br />19 <br />EC 9.2751 <br />20 Petitioners' challenge turns on the correct construction of the Eugene Code, <br />21 so we review LUBA's order to determine whether it is "unlawful in substance." ORS <br />2 <br />